LP-21-00002 Suncadia Ph. 3 Div 17 Tumble Creek - Master File (Indexed)

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Page 1 of 2 The Confederated Tribes of the Colville Reservation History/Archaeology Program (509) 634-2693 P.O. Box 150, Nespelem, WA 99155 FAX: (509) 634-2694 August 26, 2021 Kelly Bacon Staff Planner, Kittitas County Community Development Services 411 N. Ruby St. Suite 2 Ellensburg, WA 98926 RE: Suncadia Phase 3 Division 17 Tumble Creek LP-21-00002 Dear Kelly Bacon, Thank you for consulting with the Confederated Tribes of the Colville Reservation (CCT). Please be advised that the proposed undertaking lies within the traditional territories of the Wenatchi Tribe, one of twelve constituent tribes of the Confederated Tribes of the Colville Reservation (Colville Confederated Tribes [CCT]), which is governed by the Colville Business Council (CBC). The CBC has delegated to the Tribal Historic Preservation Officer (THPO) the responsibility of representing the CCT with regard to cultural resources management issues throughout the traditional territories of all of the constituent tribes under Resolution 1996-29. This area includes parts of eastern Washington, northeastern Oregon, the Palus (Palouse) territory in Idaho, and south central British Columbia. The applicant’s answers to Section B.13(a-d) of the provided SEPA checklist provide references to the original DEIS and FEIS, as well as the Suncadia MPR Conditions of Approval sections C- 21 to C-23. These sections appear to be based on recommendations made during the original cultural resource survey effort for the MountainStar Resort in 1998 (Griffin and Churchill). -We consider the scope, methods, results, and recommendations of the 1998 cultural resources survey to be woefully inadequate as a means of determining the current proposed projects’ impacts on cultural resources. This survey did not include any subsurface testing. The authors noted that “Additional resource areas undoubtedly exist within the MountainStar Resort but, due to poor ground visibility throughout the resort area, have not been identified…” The CCT does not consider such a survey to be adequate for identifying cultural resources for a project with ground disturbing activities, much less as the basis for the Suncadia MPR Conditions of Approval, and subsequent Determinations of Non-Significance. -The SEPA checklist for this project refers to sections C-21 through C-23 of the MPR Conditions of Approval as the methods to be used to assess potential impacts to resources. Section C-23 requires subsurface testing “within identified cultural constraint areas…” only. To the best of my knowledge, these “cultural constraint areas” were identified by the 1998 effort that did not include any subsurface testing and explicitly described the likelihood of additional unidentified resources. We do not belief that sufficient information currently exists to adequately answer questions B.13.(a-d) of the SEPA checklist. Index #20